Skip to content
Docs/Compliance/NIS2 & EU AI Act
Edit on GitHub

NIS2 & EU AI Act

The opensecstack ecosystem is designed around the European regulatory and threat landscape. This page maps how the 11 platforms satisfy the security measures mandated by NIS2 Directive 2022/2555 (Articles 21 and 23) and explains the additional obligations introduced by the EU AI Act (Regulation 2024/1689), which intersect with VertGuard and the projected NIS3 trajectory.

Overview

NIS2 applies to essential and important entities across the EU. It mandates appropriate technical and organisational security measures (Article 21) and requires notification of significant incidents to the national CSIRT or competent authority within defined deadlines (Article 23). The opensecstack ecosystem was built to provide a complete, evidence-generating, self-hostable implementation of these obligations.

No single platform covers every measure. The ecosystem is designed so each platform is the primary evidence source for one or two measures, with secondary contributions across others. The combination of platforms — particularly the CITADEL WORM audit chain and NIS2 Compass as the assessment hub — means auditors can trace every control back to tamper-evident, independently verifiable records.

Scope: This page covers the ecosystem-wide NIS2 mapping. Each platform's own nis2-mapping.md (in its docs/ folder) provides the full per-measure evidence package and configuration steps for that platform.

Article 21(2) measures

Article 21(2) lists ten categories of security measure that essential and important entities must implement:

RefMeasure
(a)Risk analysis and information system security policies
(b)Incident handling
(c)Business continuity and crisis management
(d)Supply chain security
(e)Security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure
(f)Policies and procedures to assess the effectiveness of cybersecurity risk-management measures
(g)Basic cyber hygiene practices and cybersecurity training
(h)Policies and procedures regarding the use of cryptography and encryption
(i)Human resources security, access control policies and asset management
(j)Use of multi-factor authentication or continuous authentication solutions

Platform coverage table

The table below maps each platform to the measures it primarily covers and any secondary contributions. Primary means the platform generates the main compliance evidence for that measure. Secondary means the platform contributes supporting evidence but is not the main record.

PlatformPrimary measure(s)Secondary measuresNotes
NIS2 Compass(a) (b) (c) — all measures (assessment hub)AllCentral compliance evidence store; integrates evidence from all other platforms and manages Art. 23 notification records
IRFlow(b) Incident handling(a) (c) (d) (e) (f) (h) (i) (j)Core incident lifecycle; WORM-anchored timeline; auto-notifies NIS2 Compass within 24-hour window for P1/P2 incidents
APIGuard(e) Vulnerability handling(a) (d) (h) (i) (j)OWASP API Top 10 coverage; scan reports constitute technical evidence for Art. 21(2)(e); CI/CD integration via SARIF export
ThreatFlow(b) (d) (e)(h)IOC enrichment for incidents; STIX 2.1 exports for NIS2 Compass; tracks supply-chain IOCs; monitors cryptographic vulnerability indicators
OpenScrub(b) (c) Availability & DDoS response(a) (e)XDP/eBPF DDoS mitigation; emits structured events to CITADEL ARBITER for Art. 23 aggregation on High/Critical attack events
VertGuard(e) AI-attack defence(a) (b) (d) (f) (h)Prompt injection, deepfake, synthetic identity, AI phishing detection; MITRE ATLAS categorisation; WORM-anchored detections; also maps to EU AI Act
OpenCSIRT(b) CSIRT operations(d) (e)TAXII 2.1 / CSAF 2.0; peer federation; Art. 23 notification support; WORM emission on advisory publication
CyberPath(g) Cyber hygiene & training(b)Docker/Wasm security labs; generates training completion records usable as Art. 21(2)(g) evidence
SecureLab(f) Effectiveness assessment(b) (e)Attack simulation and detection validation; scenario results feed effectiveness metrics
CITADEL(h) Cryptography; (i) Access controlAll (governance layer)MARSHAL 5-gate policy engine; WORM audit chain with TripleHash integrity (SHA-256 + SHA-512 + BLAKE3) and Ed25519 anchors; SoD enforcement across all platforms
sinauth(j) MFA & authenticated access(i)OAuth 2.0 / OIDC; PKCE; RS256 + JWKS; TOTP MFA; single sign-on for all platform operators
Evidence chain: For an auditor tracing a single incident, the evidence path is: IRFlow incident row → CITADEL WORM entries (one per action) → Ed25519 chain anchor signatures (tamper-evident) → Article 23 notification record in NIS2 Compass → NIS2 Compass assessment linking Art. 21(2)(b). Each step is independently verifiable even if IRFlow's database were corrupted.

Article 23 notification

Article 23 requires essential entities to notify the national CSIRT or competent authority of significant incidents within strict deadlines. The ecosystem automates the 24-hour early-warning path for the highest-severity incidents.

PhaseDeadlineEcosystem feature
Early warning24 hours after becoming awareIRFlow auto-pushes to NIS2 Compass /api/v1/notifications on creation of any P1/P2 incident. The notification runs on a detached goroutine so a slow Compass API never blocks incident creation.
Full notification72 hoursManual today; IRFlow v1.1 adds an upgrade-notification path that resubmits the incident timeline. OpenScrub emits severity High/Critical attack events to CITADEL ARBITER for aggregation.
Final report1 monthNIS2 Compass assessment export. IRFlow and ThreatFlow records are referenced as evidence artefacts.

ThreatFlow also participates in the 24-hour path: when IOC correlation raises a P1/P2 incident above NIS2 significance thresholds, ThreatFlow sets the nis2_notify_required flag on the IRFlow incident via the incidents API, triggering the same notification goroutine.

A successful notification records nis2_notified_at on the IRFlow incident row. The metric irflow_governance_calls_total{target="nis2",result="failure"} surfaces notification failures for operator alerting.

EU AI Act — VertGuard

The EU AI Act (Regulation 2024/1689) entered force in August 2024 with staggered applicability through 2027. It applies to VertGuard in two ways:

  • VertGuard as AI system operator (low-risk tier): VertGuard itself uses ML for Modules 1, 2, and 5. This makes it an AI system with obligations under the Act.
  • VertGuard as a defence tool for AI system operators: Organisations deploying LLM-powered applications are themselves AI Act-scoped. VertGuard provides the technical controls for prompt-injection blocking (Art. 14 human oversight), detection logging (Art. 12 record-keeping), and AI-attack defence (Art. 15 cybersecurity).
EU AI Act articleObligationVertGuard compliance
Art. 9Risk management systemDocumented in SECURITY.md threat model; Module 3 implements the runnable policy
Art. 10Data governanceModel + dataset registries with provenance and SHA-256 checksums
Art. 11Technical documentationFull model cards in docs/ml-models-reference.md
Art. 12Record-keeping (logging)All detections WORM-logged via CITADEL from v0.1
Art. 13TransparencyPer-detection confidence exposed; deterministic patterns separated from ML classification; C2PA signer chain exposed per detection
Art. 14Human oversightPrompt-injection blocking + appeals process via CITADEL MARSHAL gate
Art. 15Accuracy, robustness, cybersecurityPublished accuracy benchmarks; false-positive test corpus; Module 3 is the primary AI security control

NIS3 readiness (projected)

NIS3 does not yet exist as a formal instrument. Based on NIS2 Article 41's review schedule, the Commission will publish a review by October 2027; a legislative proposal is plausible for 2028–2029, with adoption 2030–2031 and transposition 2032–2033.

NIS3 is expected to move beyond NIS2's generic "network and information systems security" language and introduce explicit obligations for AI-attack defence, AI supply-chain provenance, cross-CSIRT AI-threat sharing, and post-quantum cryptographic migration. The following table shows where the ecosystem stands today against projected NIS3 requirements:

Projected NIS3 requirementVertGuard / ecosystem todayStatus
AI-system input attack defence (prompt injection, jailbreaks)Module 3 — pattern + ML classifier (Phase 4.1/4.2)Covered
Deepfake / synthetic media detectionModule 1 — C2PA in v0.1; ML deepfake in v0.5 (2027)Partial
AI-generated phishing detectionModule 2 — planned v0.5 (2027 Q3)Planned
ML supply-chain provenance (model + dataset)Model registry + SHA-256 checksums; dataset registryPartial
Cryptographic evidence chain (tamper-evident)TripleHash + CITADEL WORM + Ed25519 anchor signaturesCovered
Standardised AI-IOC format (STIX + MITRE ATLAS)ThreatFlow STIX-compatible bundle; Module 4 ATLAS taggingCovered
Post-quantum cryptographic migration mandateEcosystem PQ roadmap: hybrid Ed25519 + ML-DSA in v2.0 (2028); PQ-default in v3.0 (2030)Planned
AI-agent governance (human oversight, audit trail)CITADEL MARSHAL gate; every AI-initiated action reviewablePartial
Cross-CSIRT AI-threat sharingModule 4 ATLAS-tagged IOCs via ThreatFlow; OpenCSIRT federation Phase 3 (not yet implemented)Partial
Deployers in 2026 are not "NIS3-compliant" — NIS3 does not exist. They are NIS2 Article 21(e)-aligned and accumulating the evidence chain that NIS3 will require. The CITADEL WORM log retains evidence from v0.1 onward; setting a 7-year retention window now ensures that chain covers the full NIS3 evidence horizon before the directive is even ratified.

SIN — Security Intelligence Network — Open-source cybersecurity & compliance for the EU Digital Decade.

Apache-2.0 & AGPL-3.0 · GitHub · Contribute